New York ESCO Suggests "Strict Guidelines" For Enrollments/Drops Of Community Solar Customers, Foresees Multiple Providers Seeking To Enroll Same Customer

In comments to the New York PSC concerning utility consolidated billing for community distributed generation (CDG), EnergyMark said that the PSC should adopt "strict guidelines" governing for community solar customer enrollments and drops

"One issue we foresee is having multiple service providers trying to enroll a single Subscriber into their different community solar projects. This can result in much customer confusion, and there need to be strict guidelines for enrollments and drops, similar to the ESCO market currently," EnergyMark said

EnergyMark noted that it has partnered with BQ Energy to own and co-develop a 10 megawatt community solar project in the town of Ashford at the former site of the West Valley Nuclear Demonstration Project. EnergyMark is also the service provider for this project responsible for the customer acquisition and subscriber billing/management. "Over the last several months, EnergyMark has been actively acquiring subscribers and has experienced first-hand the questions, concerns and requirements of current and future CDG subscribers."

EnergyMark favors utility consolidated billing for CDG, agreeing with a proposal that consolidated billing should require that the subscription charge for each member be set at a percentage of value of the credit received by the CDG member

EnergyMark said that the current purchase of receivables model, which includes a discount, "is not a good fit for CDG charges as credits applied to a subscriber's invoice will decrease the overall utility bill, thus already decreasing the utility's exposure from risk of non-payment by the customer."

"We believe a fee charged to the developer during development of the project is a more fitting mechanism for the Utility to recover costs associated with a consolidated billing system. Utilities could also build software & programming costs into future delivery rates, or pull from existing System Benefits Charge (SBC) funds, to be compensated for the upfront costs," EnergyMark said

"We feel that since we are applying credits to subscribers' utility bills, this is reducing payment exposure for the utilities. We don' t think there should be a POR charge since that is more to compensate utilities for Uncollectible Expenses and payment risk. We believe utilities should be able to draw from existing SBC charges, or implement into their delivery pricing," EnergyMark said